Overview
- Headquarters
- Newport Beach, CA
- Total Firm Assets
- $1.1 billion
- Average High-Net-Worth Client Portfolio Size
- $2.7 million
- Minimum Account Size
- $500,000
Fee Structure
Primary Fee Schedule (KNIGHTSBRIDGE WEALTH MANAGEMENT FORM ADV, PART 2A WRAP BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | and above | 1.50% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $15,000 | 1.50% |
| $5 million | $75,000 | 1.50% |
| $10 million | $150,000 | 1.50% |
| $50 million | $750,000 | 1.50% |
| $100 million | $1,500,000 | 1.50% |
Clients
- High-Net-Worth Share of Firm Assets
- 80.76%
- Number of High-Net-Worth Clients
- 333
- Total Client Accounts
- 1,391
- Discretionary Accounts
- 1,247
- Non-Discretionary Accounts
- 144
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Pooled Investment Vehicles, Portfolio Management for Institutional Clients, Investment Advisor Selection
Regulatory Filings
- SEC CRD Number
- 110347
Additional Brochure: KNIGHTSBRIDGE WEALTH MANAGEMENT FORM ADV, PART 2A BROCHURE (2026-03-31)
View Document Text
450 Newport Center Drive
Suite 630
Newport Beach, CA 92660
949.644.4444
www.knightsb.com
Form ADV, Part 2A Brochure
March 31, 2026
This brochure provides information about the qualifications and business practices of
Knightsbridge Asset Management, LLC, DBA Knightsbridge Wealth Management (hereafter
referred to as “Knightsbridge”). If you have any questions about the contents of this brochure,
please contact us at 949.644.4444 or knightsbridge@knightsb.com. The information in this
brochure has not been approved or verified by the United States Securities and Exchange
Commission or by any state securities authority.
Any reference to or use of the terms “registered investment adviser” or “registered,” does
not imply that Knightsbridge, or any person associated with Knightsbridge, has achieved a
certain level of skill or training.
information about Knightsbridge
is available on the SEC’s website at
Additional
www.adviserinfo.sec.gov.
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ITEM 2 - MATERIAL CHANGES
Revised March 27, 2026
Knightsbridge reviews and updates Form ADV at least annually to confirm that it remains
current.
The purpose of this page is to inform you of any material changes since the last update to
this brochure. If you are receiving this brochure for the first time, this section may not be
relevant to you.
No material changes were made since the last update to Knightsbridge’s brochure dated
March 28, 2025.
Our complete Form ADV Part 2A & 2B may be requested by contacting our firm at 949.
644.4444 or by email at knightsbridge@knightsb.com.
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ITEM 3 - TABLE OF CONTENTS
ITEM 2 - MATERIAL CHANGES ........................................................................................................... 2
ITEM 3 - TABLE OF CONTENTS ......................................................................................................... 3
ITEM 4 - ADVISORY BUSINESS .......................................................................................................... 4
ITEM 5 - FEES AND COMPENSATION .............................................................................................. 6
ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT................... 10
ITEM 7 - TYPES OF CLIENTS........................................................................................................... 100
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ... 11
ITEM 9 - DISCIPLINARY INFORMATION ........................................................................................ 16
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS....................... 16
ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT
TRANSACTIONS AND PERSONAL TRADING .............................................................................. 17
ITEM 12 - BROKERAGE PRACTICES ............................................................................................... 18
ITEM 13 - REVIEW OF ACCOUNTS................................................................................................... 21
ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION ............................................. 22
ITEM 15 - CUSTODY.............................................................................................................................. 22
ITEM 16 - INVESTMENT DISCRETION ............................................................................................ 23
ITEM 17 - VOTING CLIENT SECURITIES......................................................................................... 24
ITEM 18 - FINANCIAL INFORMATION ............................................................................................. 25
Form ADV, Part 2B Brochure Supplement..................................................................................... 26
PRIVACY NOTICE.................................................................................................................................. 39
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ITEM 4 - ADVISORY BUSINESS
Description of Advisory Firm
Knightsbridge is an independent, 100% employee-owned limited liability company
headquartered in Newport Beach, California. Knightsbridge is registered as an investment
adviser with the U.S. Securities and Exchange Commission.
Knightsbridge was co-founded in 1998 by John Prichard, CFA®. Historical investment
results include periods under predecessor firms Canterbury Capital Services, Inc. (1992)
and Buffalo Capital Corporation (1993). John Prichard, CFA®, Kurt Beimfohr, and Miles
Yourman, CFA® currently own the firm.
Investment Advisory Services Offered
Knightsbridge offers investment advisory services directly to retail and institutional clients,
including those referred by solicitors, and through sub-advisory and wrap-fee
arrangements. The firm provides discretionary investment management services to clients
through individually managed accounts. Services include design, implementation, and
continued monitoring of the client’s account. Knightsbridge offers financial planning advice
as a courtesy to its clients. On occasion and at its sole discretion, Knightsbridge may assist
clients on a non-discretionary basis.
Client investments may include over the counter and exchange-traded securities such as
common and preferred stocks and bonds, American Depository Receipts (ADRs), foreign
securities listed on foreign exchanges (ordinaries), Real Estate Investment Trusts (REITs),
closed-end and open-end mutual funds, exchange-traded funds (ETFs), interests in
exchange-traded and private limited partnerships or funds that may be illiquid, fixed-income
securities such as corporate, mortgage, government and municipal bonds, and floating rate
notes. Accounts may at times hold material positions in cash or cash equivalents.
We describe the material investment risks associated with client investments under the
heading Investing Involves Risks in Item 8 below.
We describe the fees charged for investment management services below under Item 5 -
Fees and Compensation.
We discuss our discretionary authority below under Item 16 - Investment Discretion.
Sub-Advisory Relationships and Wrap Programs
Clients can also access Knightsbridge’s investment advisory services through unaffiliated
third parties under a sub-advisory relationship or through a wrap fee program. These
services are offered as separately managed accounts.
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The fees Knightsbridge receives under these arrangements are described below under
Item 5 - Fees and Compensation.
Tailored Services and Client Imposed Restrictions
Clients may request restrictions on their account, such as a minimum level of cash or
avoidance of specific securities or security types. Any such limitation may add client-
imposed risk of loss and reduction of investment return. It is the client’s responsibility to
keep Knightsbridge informed of any changes to their investment objectives or restrictions.
Wrap Fee Programs
Knightsbridge serves as a third-party manager to Wedbush Securities, Inc. in the Advisory
Services Program sponsored by FDx Advisors, Inc. As part of this program, the client pays a
single bundled fee to the company offering the wrap fee program, instead of paying
separately for Knightsbridge’s advisory services, commissions on transactions, custodian
fees, and other transaction-related fees. The company sponsoring the program then pays
Knightsbridge a portion of the wrap fee for investment management services.
Knightsbridge chooses investments for clients in wrap fee programs the same way we
make investment decisions for other client accounts with the same or similar investment
strategy. However, because wrap fee programs are often offered by or connected to a
broker-dealer, we will generally use that broker-dealer when placing trades for those
accounts, unless we cannot achieve best execution in doing so. If we use a different broker,
that broker might charge the client transaction costs in addition to those they are already
paying for under the wrap fee.
Knightsbridge also sponsors and acts as portfolio manager in its own wrap fee program.
Knightsbridge’s wrap fee program is described in our Form ADV Part 2A Appendix 1 Wrap
Fee Program Brochure.
Services to Related Private Fund
Knightsbridge is the investment manager to KWM Asymmetric Opportunities Fund, LP, a
private fund (the “Fund”). KAO General Partner, LLC, a California limited liability company,
serves as the general partner (the “GP” or General Partner”) of the Fund. Knightsbridge is
the sole member of the GP and the owners of Knightsbridge are also the Managing
Members of the GP. The GP has delegated the investment management responsibilities for
the Fund to Knightsbridge. See also Item 10 – Other Financial Industry Activities and
Affiliations, below. The Fund is a Delaware limited partnership and is not publicly offered or
traded. The Fund is only available to “accredited investors” as the term is defined by Rule
501(a) of Regulation D of the Securities Act of 1933. See also Item 5 – Fees and
Compensation below.
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Retirement Plan Services
Knightsbridge offers ERISA fiduciary and non-fiduciary services to sponsors of qualified
retirement plans (“Plan(s)”) and their plan participants. Our services will be outlined in each
investment advisory agreement with the plan and may include any of the following:
Investment selection and monitoring.
•
• Review Plan documents to confirm consistency with the trustee(s) instructions.
• Provide guidance to trustee(s) on responsibilities for administering the Plan.
• Assist in obtaining the necessary initial and ongoing ERISA bonding.
• Recommend a custodian for the Plan assets.
• Work with the trustee(s) to create an investment policy.
• Communicate with the Plan record keeper regarding various reporting and testing
requirements.
• Assist eligible employees in opening individual 401(k) accounts.
• Provide educational materials to facilitate the participants’ management of their
individual accounts and the resolution of service-related issues with the custodian.
• Assist the trustee(s) in opening a corporate 401(k) account to facilitate allocation of
employee elective deferrals and any employer nonelective contributions.
• Consult with the trustee(s) or other service providers authorized by the trustee(s) to
establish processes for funding participant accounts.
• Facilitate certain other required actions stipulated within the Plan including distributions
and loans in coordination with the custodial service team and Plan record keeper.
The Knightsbridge Wrap Fee Program is not available to participants of these ERISA plans.
Assets Under Management
Knightsbridge manages client assets in discretionary and non-discretionary accounts on a
continuous and regular basis. As of December 31, 2025, the total amount of discretionary
assets under our management was $1,030,039,248 and the total amount of non-
discretionary assets under our management was $88,464,534.
ITEM 5 - FEES AND COMPENSATION
Fee Schedule
Investment Advisory Services
Knightsbridge charges an advisory fee for investment advisory services based on a
percentage of the client’s total assets under management. Our maximum annual fee
charged is 1.5%. The specific advisory fees are set forth in your Investment Management
Agreement.
Other Fee Arrangements
There may be certain circumstances where our standard fee schedule does not apply.
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1. Knightsbridge reserves the right to negotiate fees.
2. We may reduce or waive fees for employees of the firm and their family members or
other parties.
3. With certain clients, we have negotiated a performance-based incentive fee. Item 6 –
Performance-Based Fee and Side-by-Side Management contains more information
on these arrangements.
4. In some cases, Knightsbridge manages portfolios for clients of third-party advisory,
consulting, or brokerage firms, or provides non-discretionary investment advice for a
reduced fee.
5. Sometimes a client may be introduced to Knightsbridge by a promoter. In these
cases, the fee schedule in the client’s agreement may be specific to that particular
promoter and may vary from our standard fee schedule. For additional details about
our referral arrangements, see Item 14 – Client Referrals and Other Compensation.
6. Certain client agreements may feature a fee schedule which declines over time.
Billing Method
Knightsbridge charges fees in advance or arrears depending on the nature of the client
relationship.
Fees are calculated quarterly based on the portfolio value of the client’s assets under
management, including accrued interest, at the close of business on the last day of each
calendar quarter. All assets in any form in the client’s account are considered in determining
the portfolio value, including cash balances, money market assets, equity and debt
positions.
Knightsbridge will pro-rate fees for any periods where it managed the account for less than
a full calendar quarter (such as inception or termination of an account). Fees are due no
later than 30 days after the calendar quarter.
Clients generally authorize Knightsbridge to have advisory fees withdrawn directly from
their custodian account. For those custodians where Knightsbridge has the ability to debit
fees, Knightsbridge will instruct the custodian to automatically withdraw its advisory fee
from the client’s account on a quarterly basis. For those custodians where Knightsbridge
does not have authority to debit fees, Knightsbridge will send an invoice to the custodian
displaying the amount of the fee and the fee calculation. Knightsbridge may also
accommodate client requests to be billed directly.
All clients will receive brokerage statements from the custodian no less frequently than
quarterly. The custodian statement will reflect the deduction of the advisory fee for those
clients who authorize the advisory fees to be withdrawn directly from their custodian
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account. It is the client’s responsibility to verify the accuracy of the fee calculation. The
custodian will not determine whether the fee is properly calculated.
Termination of Agreements
Either party may terminate the agreement upon ten (10) days written notice to the other
party; however, the client can revoke our discretionary authority over the account at any
time; the client will then be responsible for paying fees for services through the effective
date of termination. Any notice shall be deemed effective upon actual receipt of written
acknowledgement.
Upon notice of termination, Knightsbridge will calculate the final fees due for services
provided through the date of termination. Any advisory fees earned for services provided
will be due upon termination. Knightsbridge will refund any unearned fees, prorated to the
effective date of termination.
Sub-Advisory Relationships and Wrap Programs
The annual fees Knightsbridge receives through a third-party wrap program is 0.50%. The
fees Knightsbridge receives for providing investment management services do not include
other fees charged by the third-party adviser to the client. Fees under this program are
billed in advance, and Knightsbridge is paid by the third party.
Clients using Knightsbridge as a sub-adviser through third-party adviser or wrap fee
programs may terminate management services per the terms in the agreement, which vary
by program.
Services to Related Private Fund
The Fund offers two (2) classes of limited partnership interests (the “Interests”):
Management Fee Class Interests and Performance Allocation Class Interests. A Limited
Partner investing in the Fund may subscribe for one, and only one, of either (i) Management
Fee Interests (each such investor a “Management Fee Limited Partner”) or (ii) Performance
Allocation Interests (each such investor a “Performance Allocation Limited Partner”). The
terms applicable to each class of Interests are substantially the same, except that the
Management Fee Interests are subject to the Management Fee but not the Performance
Allocation (each as defined herein) and the Performance Allocation Interests are subject to
the Performance Allocation but not the Management Fee. All Performance Allocation
Limited Partners must be (i) “accredited investors” as defined in Rule 501(a) of Regulation D
under the Securities Act and (ii) “qualified clients” as defined in Rule 205-3 under the
Advisers Act. Thus, all Limited Partners who are not both “accredited investors” and
“qualified clients” must be Management Fee Limited Partners.
Management Fee Limited Partners are subject to a quarterly management fee (the
“Management Fee”) equal to 0.375% (1.5% annually), payable in arrears, of each
Management Fee Limited Partner’s capital account balance as of the end of such calendar
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quarter. Performance Allocation Limited Partners are subject to a quarterly performance
profit allocation (the “Performance Allocation”) in an amount equal to 12.5% of each
Performance Allocation Limited Partner’s ratable share of the Partnership’s profits for such
calendar quarter (the “Performance Allocation Period”), provided that such profits exceed
such Performance Allocation Limited Partner’s “high-water mark.”
Investors should review the Fund’s offering documents for a complete description of the
fees and expenses, any minimum capital account requirements, and withdrawal provisions,
before investing in the Fund.
Other Fees and Expenses
Except for clients participating in a wrap fee program or where otherwise agreed upon with
the client, Knightsbridge’s fees do not include custodian fees. Clients pay all brokerage
commissions, wire fees, SEC fees, stock transfer fees, and/or other similar charges
incurred in connection with transactions in accounts, from the assets in the account. Clients
may also incur charges imposed by closed-end and open-end mutual funds and exchange-
traded funds which are disclosed in the fund’s prospectus (i.e., fund management fees,
operating expenses, or variable annuity fees). These charges are in addition to the fees
clients pay to Knightsbridge. See Item 12 - Brokerage Practices below for more information
about the broker-dealers we use and the benefits we may receive from client transactions.
Knightsbridge does not accept compensation for the sale of securities or other investment
products, including asset-based sales charges.
In addition to Knightsbridge’s investment advisory fee and other such fees, Clients in a
Personalized Equity Indexing strategy may also pay all margin interest and fees, and/or
other similar charges incurred in connection with transactions in accounts, from the assets
in the account. Such fees include all brokerage commission costs for securities
transactions affected for the Client’s account. Any fees described as
Registration/Handling/Postage/Transfer Fees or fees imposed by the Securities and
Exchange Commission shall be borne by the client account. In addition, if a client agrees to
use margin to purchase assets that an unaffiliated third party will manage as part of the
Personalized Equity Indexing strategy, Knightsbridge will include the entire market value of
the margined assets when computing its advisory fee. See ITEM 8 – Methods of Analysis,
Investment Strategies and Risk of Loss for additional information on the use of margin. As
part of the Personalized Equity Indexing strategy, Clients will pay a separate and
additional investment advisory fee under an Investment Advisory Agreement to an
unaffiliated third-party sub-adviser.
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ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE
MANAGEMENT
Knightsbridge typically charges asset-based fees for its investment management services.
Knightsbridge has also negotiated with certain clients a performance-based incentive fee.
We may only offer performance-fee arrangements to clients that meet certain internal and
regulatory qualifications. Specifically, clients meeting assets under management or net
worth tests of SEC Rule 205-3 under the Investment Advisers Act of 1940 may elect to
have assets managed by the firm on a performance compensation basis.
Knightsbridge may give advice to or take action for performance-based incentive fee
accounts that differs from advice given to or action taken for other managed accounts, as
the investment objectives and risk tolerance for these accounts may differ from other
managed accounts.
Incentive fee clients do not pay an asset-based fee but are charged performance-based
fees on a percentage of the portfolio net profits (generally 20% of profits) based on
realized and unrealized gains and losses over a one-year period. Performance fee rates
have “high water marks” – losses are carried forward and must be made up before any
performance-based incentive fees are due. Clients under these arrangements should
review the fee agreement for more specifics about how the incentive fee is charged. These
arrangements may create a conflict of interest for Knightsbridge as it may have incentives
to allocate investment opportunities that it believes might be the most profitable to
accounts charged performance-based or higher asset-based fees.
Additionally, Performance Allocation Limited Partners of the Fund are subject to a quarterly
performance profit allocation (the “Performance Allocation”) subject to the Performance
Allocation Limited Partner’s “high-water mark.” The Fund’s fees are described above in
Services to Related Private Fund of Item 5 and more completely in the Fund’s offering
documents. Consequently, Knightsbridge may have conflicts of interest in allocating
investments among the Fund and other managed accounts.
Knightsbridge has adopted policies and procedures reasonably designed to allocate
investment opportunities between accounts on a fair and equitable basis over time and
prevent non-suitable investments in client accounts.
ITEM 7 - TYPES OF CLIENTS
Knightsbridge offers discretionary investment advisory services to retail and institutional
clients, including individuals, high net worth individuals, trusts and estates, individual
participants of retirement plans, pension and profit-sharing plans, charitable organizations,
and businesses. In addition, we provide investment management services to the Fund.
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Account Requirements
Generally, Knightsbridge requires a minimum account size of $500,000 to open an account.
We may combine family accounts of retail clients to meet the account size minimum.
Knightsbridge may reduce or waive the account minimum requirements at its discretion.
Knightsbridge may recommend that qualified clients participate in securities lending
programs offered by their custodians.
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND
RISK OF LOSS
Investment Philosophy
Knightsbridge focuses on building low-cost, tax-efficient investment portfolios. With all
strategies, we seek to deliver attractive risk-adjusted returns. We also employ active risk
management in many of our strategies. As such, cash equivalents, sometimes used as a
defensive tool, may at times represent a significant portion of the client’s account, including
up to 100% of our Managed Income strategy.
Investment Strategies
Knightsbridge offers the following strategies:
Opportunistic Value Equity strategy: A growth-oriented active equity strategy
For investors seeking capital appreciation. We attempt to generate strong returns by
investing among stocks exhibiting either a “structural investment anomaly” which may be
temporarily depressing price or a “signaling investment anomaly” indicating undervaluation
compared to intrinsic value. We also like to have the following qualities present:
manageable debt load; cash generative business; good returns on capital; alignment of
management; revenue growth.
Long Term Quality Equity strategy: A tax-optimized active equity strategy
For investors seeking long-term growth who benefit from deference of tax realization. We
invest in quality companies capable of ‘compounding’ tax efficiently over a holding period of
many years. We define a quality company as one which possesses: consistency in
profitability; good returns on capital; no major secular pressures; little risk of obsolescence;
easily manageable debt. With higher quality companies, we invest where valuations allow
for adequate absolute returns. A reasonable starting valuation allows business cash flows,
not perceptions, to ultimately drive investment results. We do not stretch for rock-bottom
valuations that are often warning signs of business deterioration and we avoid excessively
levered companies.
Managed Income: An actively managed fixed-income strategy
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For conservative investors seeking daily liquidity and more consistent positive returns. Our
Managed Income strategy targets a positive total return during all one-year periods through
active risk management with an emphasis on fixed-income securities. Investors in our
Managed Income strategy should experience low downside principal volatility.
Balanced: Includes allocation to both equity and fixed-income strategies
Balanced portfolios blend varying degrees of equity and fixed-income exposure, utilizing the
above strategies, to tailor the level of risk and potential return to meet each individual
client’s objectives. Our Tax Optimized Balanced Strategy is employed for taxable accounts.
Investments will vary depending on clients’ tax brackets. Our Tax Agnostic Balanced
Strategy is employed for non-taxable accounts.
Personalized Equity Indexing: Includes allocation to equities, including those potentially
bought on margin or a short positionDepending on the tax loss harvesting strategy
employed, investors either get straight equity exposure with or without factor tilts, or with
specific tilts designed by the subadvisor intended to generate alpha as well as beta. The
subadvisors generally tax-harvest positions that lose value below their basis and thus allow
for the cumulation of taxable losses while the other positions perform to the market plus or
minus any alpha.
Investment Strategy of Related Private Fund
The Fund’s strategy is to buy and hold California Carbon Allowances (“CCAs”) and carbon
allowances issued by other jurisdictions (together with the CCAs, the “Allowances”) in
anticipation of expected appreciation during the next 3 to 7 years. The Fund anticipates
establishing these positions by taking long futures positions in and accepting physical
delivery of the Allowances. It is anticipated that the Fund will dissolve if and when CCAs
reach prices near the top of the range possible as specified by the California Cap-and-
Trade Program. The Fund may also pursue its investment strategy through investments in
publicly traded equities, options, exchange-traded funds and other securities.
Methods of Analysis
Our portfolio management incorporates strategic and tactical asset allocation and applies
both fundamental and technical research and analysis. In addition to our own internal
research and analysis, we receive research and analysis from external sources including
brokerage firms and mutual fund companies. Some of this research and analysis is
available at no cost, others we purchase.
Step One: Objective Setting
We seek to obtain a clear understanding of the client’s investment goals based on the
client’s expectations and time horizon, as well as the client’s ability and willingness to
assume risk. We use this information to establish an appropriate portfolio strategy
consistent with the client’s investment objectives.
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Step Two: Asset Allocation
Our asset allocation process begins with our assessment of the impact of various factors
such as economic indicators, monetary policy and political developments on the financial
markets. We then implement a portfolio strategy that is consistent with the client’s goals
and objectives by deploying assets across equity (stocks), fixed-income (bonds) and other
asset classes (cash, gold, commodities, etc.).
Step 3: Sector Allocation
Sector selection adds further diversification to the portfolio matrix by allocating across a
variety of sectors which may or may not include large, mid or small cap, value or growth
equity stocks and funds, as well as various fixed-income classes, such as corporate (both
investment grade and below investment grade), government (Treasury, agency, municipal),
mortgage and asset backed.
Step 4: Investment Selection
Fund Selection: While we primarily select funds with a demonstrated track record of
consistently superior returns, it is important to look beyond historical performance and
understand the characteristics of each fund. For active funds, we regularly conduct internal
research to ensure we have a thorough understanding of the fund investment style. For
passive funds, we regularly monitor fees and tracking error.
Stock Selection: When investing in stocks in taxable accounts, we generally invest for the
long-term, in quality businesses, seeking an adequate absolute return in a tax efficient
manner. We define a quality company as having: consistent profitability; decent returns on
capital; no major secular pressures; little risk of obsolescence; easily manageable debt.
When investing in stocks in tax-exempt accounts, we generally invest among stocks
exhibiting “investment anomalies” and/or where our analysis indicates intrinsic value in
excess of current stock price.
Fixed-Income Selection: In evaluating fixed-income securities for balanced accounts,
Knightsbridge considers the financial strength of the issuer, call provisions, liquidity factors,
credit spreads, and bond insurance in selecting bonds for purchase. Knightsbridge relies on
credit rating agencies such as Standard & Poor’s and Moody’s to help determine the
financial strength of issuing creditors. We also use prospectuses, other relevant information
from bond underwriters, and/or sources of market data to help in analysis and selection of
fixed-income securities. Knightsbridge may solicit bids from several sources to obtain the
most attractive price/yield on purchase or sale.
Step 5: Portfolio Review Process
The portfolio review process consists of the daily monitoring of the stock and bond markets
and based on our models, the increase or reduction of the client’s equity and/or fixed-
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income assets. In addition, sector allocations are changed based upon our forward-looking
assessment of investment risks and opportunities within the current economic cycle.
Investing Involves Risks
All investment programs have certain risks that are borne by the investor, including the risk
that an investor may lose part or all his or her investment. Past performance is not
indicative of future results; therefore, investors should not assume future performance will
be profitable.
Prior to entering into an agreement with Knightsbridge, the client should carefully consider:
Investing in securities involves risk of loss which clients should be prepared to bear;
1.
2. Securities markets experience varying degrees of volatility;
3. Certain securities may be illiquid;
4. Account values will fluctuate and at any time be worth more or less than the amount
invested;
5. Clients should only commit assets available for investment on a long-term basis;
6. Accounts may hold a limited number of individual stocks, i.e., potentially 15 or fewer,
in which case diversification would be limited.
7. Accounts may hold high levels of cash at times, potentially up to 100%. This induces
timing risk and the potential to miss out on investment gains.
8. Accounts may not be fully invested at inception. This induces timing risk and the
potential to miss out on investment gains.
9. Knightsbridge may trade outside of normal stock market hours. Trading before or
after these hours; there are no guarantees that we will obtain the price we want or
that the order will fill at all.
Investors should be aware that accounts are subject to the following risks:
Specific Security Risks: Knightsbridge generally seeks investment strategies that do not
involve significant or unusual risk beyond that of the general domestic and/or international
equity and fixed-income markets. Other strategies such as using margin or leverage can be
used when Client’s utilize an unaffiliated third-party as part of a Personalized Equity
Indexing strategies, or Knightsbridge deems it appropriate for a particular account or given
market condition. While the use of margin borrowing or leveraged funds can increase
returns, it can also magnify losses in the event of a significant downturn in the market.
Clients are responsible for the payment of any margin charges. These specific strategies
can increase risks independent of the many risks inherent to investing. Investing in
securities involves risk of loss that Clients should be prepared to bear. Securities markets
experience significant degrees of volatility. Over time, a Client’s assets may fluctuate and at
any time be worth more or less than the amount invested.
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Market Risk: The price of a stock, bond, mutual fund, ETF or other security may drop in
reaction to tangible and intangible events and conditions. This type of risk is caused by
external factors independent of a security’s underlying circumstance.
Foreign Risk: Investments in international securities include exposure to risks such as
currency fluctuations, foreign taxes and regulations, and political instability.
Capitalization Risk: Younger and smaller companies may be hindered as a result of limited
resources or less diverse products or services, resulting in more volatility than larger, more
established companies.
Interest Rate Risk: Fluctuations in interest rates may cause investment values to fluctuate.
For example, when interest rates rise, yields on existing bonds become less attractive,
causing their market values to decline. Declining interest rates increase reinvestment and
call risk, whereby interest income and return of principal would be invested at lower
prevailing rates. In low interest rate environments, advisory fees may exceed cash yields.
Legal/Regulatory Risk: Certain investments or issuers of investments may be affected by
changes in state or federal laws, tax laws, or in the prevailing regulatory framework under
which the investment or issuer is regulated, negatively impacting the overall performance of
such investments.
Credit Risk: The issuer of a security may be unable to make interest or dividend payments
and/or repay principal when due. A downgrade to an issuer’s credit rating or a perceived
change in an issuer’s financial strength may negatively affect a security’s value.
Liquidity Risk: Certain assets may not be readily converted into cash or may have a limited
market in which they trade, resulting in unfavorable pricing when selling. Private
partnerships or funds may significantly restrict the ability to redeem funds. Limitations may
include a waiting period before initial redemption, periodic redemptions which require
advance notice, acceptance of only a portion of requested redemption, and other
restrictions which limit control on the timing and amount of redemption. Knightsbridge is
not responsible for, and bears no liability associated with, such limitations.
Inflation Risk: Purchasing power erodes at the rate of inflation, so the value of investments
in the future may not be worth what they are today.
Cybersecurity Risk: Investment advisers, including Knightsbridge, must rely in part on
network technologies to conduct their businesses. Such networks may be at risk of
unauthorized access for purposes of misappropriating sensitive information, corrupting
data, or causing operational disruption. Knightsbridge has established a business continuity
plan intended to reduce such risks and safeguard our data; nevertheless, cyber incidents
could potentially occur.
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Private Fund Risk
Investment in private funds is speculative and involves a substantial degree of risk, which is
why investing in private funds may not be suitable for all investors and are intended for
sophisticated investors who can accept the risks associated with its investments. The
investments may lose all or a substantial portion of their value and investors must be
prepared to bear the risk of loss of their investments. Investors will not have recourse
except with respect to the assets of the fund. The investments made by a private fund may
be very illiquid, and consequently the private fund may not be able to sell such investments
at prices that reflect our assessment of their value or the amount paid for such investments
by the private fund. Illiquidity may result from the absence of an established market for the
investments as well as legal, contractual or other restrictions on their resale by the private
fund and other factors. The fund documents outline important information for investors.
Investors should review all fund document(s) carefully and consider conducting additional
due diligence before investing in any private fund.
ITEM 9 - DISCIPLINARY INFORMATION
Knightsbridge and its personnel seek to maintain the highest level of professionalism,
integrity, and ethics. Knightsbridge does not have any disciplinary information to disclose.
The firm and all its past and current principals have never been sued or sanctioned by the
Securities and Exchange Commission (“SEC”).
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND
AFFILIATIONS
Proprietary Related Private Fund
Knightsbridge is the investment manager to KWM Asymmetric Opportunities Fund, LP, a
private fund (the “Fund”). KAO General Partner, LLC, a California limited liability company,
serves as the general partner (the “GP” or General Partner”) of the Fund. Knightsbridge is
the sole member of the GP and the owners of Knightsbridge are also the Managing
Members of the GP. The GP has delegated the investment management responsibilities for
the Fund to Knightsbridge. The Fund is a Delaware limited partnership and is not publicly
offered or traded. The Fund is only available to “accredited investors” as the term is defined
by Rule 501(a) of Regulation D of the Securities Act of 1933. See also Item 5 – Fees and
Compensation. The Fund’s offering documents provide additional information on these
standards. Prospective investors in the Fund receive the offering documents. This Form
ADV Part 2A Brochure is not an offer to sell, or a solicitation of an offer to purchase,
membership interests in the Fund. Such an offer can only occur when the prospective
investor receives the offering documents.
Knightsbridge’s interest in the Fund raises a conflict of interest in recommending the private
fund to clients. We discuss this conflict under Private Fund Interests in Item 11, below.
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ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN
CLIENT TRANSACTIONS AND PERSONAL TRADING
Code of Ethics
Knightsbridge owes clients the highest level of trust and fair dealing. As part of our fiduciary
duty, we place the interests of clients ahead of the interests of the firm and our personnel.
We have adopted a Code of Ethics that emphasizes the high standards of conduct that
Knightsbridge seeks to observe. Knightsbridge personnel are required to conduct
themselves with integrity at all times and follow the principles and policies detailed in our
Code of Ethics.
Knightsbridge’s Code of Ethics addresses specific conflicts of interest that could likely
arise. Knightsbridge personnel are required to follow clear guidelines from the Code of
Ethics in areas such as gifts and entertainment, other business activities, and adherence to
applicable federal securities laws.
Knightsbridge will provide a complete copy of the Code of Ethics to any client or
prospective client upon request.
Personal Trading Practices
Knightsbridge personnel are subject to personal trading policies governed by the Code of
Ethics. Personnel may trade the same securities recommended to clients. Personal trading
presents a potential conflict of interest as there is potential to favor our personal accounts
over client accounts when allocating trades or trading ahead of clients.
Our policies to address these conflicts include the following:
1. We seek to always put the best interests of clients first and to never place our
interests ahead of clients.
2. We prohibit trading in any manner that takes advantage of our knowledge of client
transactions.
3. Knightsbridge personnel must request pre-clearance from our Chief Compliance
Officer, or her designee, if they wish to purchase or sell a security that is commonly
owned by clients, that is being considered for purchase or sale, IPOs, limited
offerings, private placements or public or private offerings of interests in limited
partnerships or any thinly traded securities. Direct obligations of the U.S.
government, some short-term debt securities and CDs, money market funds and
mutual funds do not need to be pre-cleared.
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4. Knightsbridge employs a trade rotation policy. Trades of our personnel are always
placed last in the rotation. We may however execute client and employee accounts
together in the same custodial block. Trade execution prices received by personnel
versus clients will vary depending upon timing of execution.
5. These policies are intended to protect the interests of clients. We may make
exceptions where we feel clients would not be harmed, and in certain strategies due
to overall liquidity and trading management.
Participation or Interest in Client Transactions
A client may need to sell a security that we think is a good fit for another client’s account. In
this case, we may internally cross the security from the selling client to the buying client’s
account, if in the best interests of both clients. Usually, this situation arises with fixed-
income securities where both clients benefit through better pricing by crossing the security
instead of going into the open market to complete separate transactions.
All internal cross transactions will be priced at the independent current market price of the
security. We will also consider any additional fees charged by the broker/custodian.
Cross trades are an exception to Knightsbridge’s normal operating procedures and will only
be affected when it is of conspicuous advantage to both accounts in the absence of
appropriate and comparable alternatives.
Private Fund Interests
Knightsbridge is the investment manager to KWM Asymmetric Opportunities Fund, LP, a
private fund (the “Fund”). KAO General Partner, LLC, a California limited liability company and
related person of Knightsbridge, serves as the general partner (the “GP” or General Partner”)
of the Fund. See also Item 10 – Other Financial Industry Activities and Affiliations, above.
Some of our advisory clients are also investors in the Fund. Because Knightsbridge has an
interest in the Fund, we benefit when we recommend that clients invest in the Fund. To
address this conflict of interest, Knightsbridge only offers the Fund interests to clients who
meet the requisite income and/or net worth requirements and where we believe that the
investment is appropriate for the client based on the client’s ability to accept the risk. Clients
will receive the offering documents and full disclosure of known risks before investing.
ITEM 12 - BROKERAGE PRACTICES
The Custodians We Use
Knightsbridge does not maintain custody of your assets, although we may be deemed to
have custody of your assets if you give us authority to withdraw assets from your account
(see Item 15 - Custody, below). Your assets must be maintained in an account at a
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“qualified custodian,” generally a broker-dealer or bank, and you open an account by
entering into an account agreement directly with them. Certain privately offered securities
may qualify for an exemption and are held directly with the fund sponsor rather than a
qualified custodian. Knightsbridge may provide the names of certain custodians as options
for a client to consider, typically Fidelity Investments (“Fidelity”) and Charles Schwab & Co.,
Inc. (“Schwab”) and may assist you in opening an account. Knightsbridge is independently
owned and operated and is not affiliated with Fidelity or Schwab. These custodians hold
your assets in a brokerage account and buy and sell securities at our instruction. Conflicts
of interest associated with these arrangements are described below as well as in Item 14 -
Client Referrals and Other Compensation.
Factors Considered in Selecting Broker-Dealers for Client Transactions
When determining the terms that a custodian/broker provides are advantageous when
compared with other available providers, we take into account a wide range of factors,
including:
• Transaction execution services and asset custody services (generally without a
separate fee for custody)
• Capability to execute, clear, and settle trades (buy and sell securities for your
account)
• Capability to facilitate transfers and payments to and from accounts (wire transfers,
check requests, electronic fund transfers, etc.)
• Breadth of available investment products (stocks, bonds, mutual funds, exchange-
traded funds, etc.)
• Availability of investment research and tools that assist us in making investment
decisions
• Quality of services
• Competitiveness of the price of those services (commission rates, other fees, etc.)
• Reputation, financial strength, security and stability
• Prior service to us and our clients
• Availability of other products and services that benefit us, as discussed below
Fidelity and Schwab do not generally charge for custody services. They are compensated
by other fees such as commissions or other fees on trades they execute or settle into your
account, earned interest on the uninvested cash in your account, and “prime broker” or
“trade away” fees for trades executed by a different broker-dealer and are settled into your
account. To minimize your trading costs, we “trade away” only when we determine it is in
your best interest.
Fidelity and Schwab may provide products and services that benefit us but do not directly
benefit you or your account. These products and services assist us in managing and
administering our clients’ accounts and generally include investment research, software and
other technology that provide access to client account data, trade execution and allocation,
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and pricing and market data. Fidelity and Schwab may also offer other services intended to
help us manage and further develop our business enterprise, such as educational
conferences and publications on practice management. These services can create a
conflict of interest because they are an incentive for us to recommend Fidelity or Schwab.
However, we believe such a recommendation is supported by the scope, quality, and price
of services and therefore in the best interests of our clients.
Aggregation and Allocation of Transactions
Knightsbridge may aggregate orders for clients in the same securities in an effort to seek
best execution, negotiate more favorable commission rates, and/or allocate differences in
prices equitably among our clients.
Based on our management process and the investments we recommend, there may be
times where we cannot or choose not to aggregate client trades or where trading
opportunity for a particular security is limited. Knightsbridge may choose not to implement
or aggregate a trade order across all accounts if, in our view, it would not be in the best
interest of certain clients. For example, a trade might not be allocated to an account with
client-imposed restrictions or which lacks adequate funds available for an investment. In all
circumstances, Knightsbridge attempts in good faith to allocate trades and investment
opportunities among clients in a manner that, over time, is equitable to all our clients.
When aggregating orders and placing trades, Knightsbridge will observe the following
procedures:
1. We will only aggregate trades when consistent with our duty to seek best execution
for our clients.
2. No client account will be favored over any other client account within a trading block.
3. Each account that participates in an aggregated transaction will participate at the
average of the executed share price for that transaction.
4. Knightsbridge employs a trade rotation policy. Trades of our personnel are always
placed last in the rotation. We may however execute client and employee accounts
together in the same custodial block. Overall liquidity and trading management of
certain strategies are an exception to this policy. Trade execution prices received by
personnel versus clients will vary depending upon timing of execution.
5. Trades are allocated/created at the account level and then aggregated into a block
before an order is transmitted to a broker for execution (Pre-Allocation Order). In
rare circumstances where timing is critical and we determine it would be in clients’
best interests to promptly begin trading, we may transact in a security without a Pre-
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Allocation Order. In such circumstances, allocations will be determined within four
hours of beginning the trading exercise.
6. If the aggregated transaction is filled entirely, it will be allocated among the accounts
listed on the Pre-Allocation Order. If the order is partially filled, we will typically
allocate on a random basis. Overall liquidity and trading management of certain
strategies are an exception to this policy and will be allocated proportionately.
7.
In particular circumstances, we may allocate on a pro-rata basis according to the
following methods:
a. When only a small percentage of the order is executed, with respect to
purchase allocations, allocations may be given to accounts high in cash;
b. With respect to sale allocations, allocations may be given to accounts low in
cash;
c. We may allocate shares to the account with the smallest order, or to the
smallest position, or to an account that is out of line with respect to security
or sector weightings, relative to other portfolios with similar mandates;
d. We may allocate to an account with investment guidelines prohibiting
e.
purchase of other securities;
If an account reaches an investment guideline limit and cannot participate in
an allocation, we may reallocate shares to other accounts. For example, this
may be due to unforeseen changes in an account’s assets after an order is
placed.
We will document the reasons for any deviation from a random allocation.
ITEM 13 - REVIEW OF ACCOUNTS
Account Reviews
Knightsbridge manages portfolios through a continuous review process (tactical allocation)
plus a regular periodic review process (strategic allocation). These portfolio reviews are
conducted by an officer of the firm.
The continuous review process consists of the daily monitoring of the stock and bond
markets, our analysis of the economic climate and the signals provided by tactical decision
models. Reviews may result in the increase or reduction of the clients’ equity and/or fixed-
income allocation.
All accounts are reviewed on a timely basis to verify the accuracy of individual account
transactions at the time a transaction is made. These transaction reviews are conducted by
administrative personnel under the direct supervision of an officer of Knightsbridge.
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Account Reporting
On a quarterly basis, clients typically receive a statement of account performance for their
accounts under our management, along with written commentary discussing market
environment and important shifts in sentiment, valuation and outlook. Additionally, the
custodian of client assets will provide statements at least quarterly which detail account
securities holdings and account cash flows. Transaction confirmations will be provided by
the clearing broker at least quarterly.
When Knightsbridge manages the client’s account under a third-party sub-advisory or wrap
fee program, Knightsbridge does not customarily provide individual reporting to the client.
ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION
Brokerage Support Products and Services
We receive an economic benefit from broker-dealers/custodians in the form of the support
products and services they make available to us and other independent investment advisors
whose clients maintain their accounts at the custodian. These products and services, how
they benefit us, and the related conflicts of interest are described above (see Item 12 –
Brokerage Practices). We do not base particular investment advice, such as buying
particular securities for our clients, on the brokerage products and services available to us.
Referral Arrangements
If an unaffiliated promoter introduces a client to Knightsbridge, we may compensate that
promoter through direct or indirect compensation in accordance with the requirements of
Rule 206(4)-1 of the Investment Advisers Act of 1940, and any corresponding state
securities law requirements. Knightsbridge pays any referral fee to the promoter from our
standard investment advisory fee.
The promoter will disclose at the time of the solicitation whether they are or are not a
current client of the firm; whether they will receive any cash or non-cash compensation for
the referral; and a statement that the receipt of compensation for a referral creates a
conflict of interest. In addition, the promoter will provide each prospective client with a copy
of a written disclosure statement disclosing the terms and conditions of the arrangement
between Knightsbridge and the promoter, including the compensation the promoter will
receive from Knightsbridge and any material conflicts of interest on the part of the
promoter as a result of the referral arrangement.
ITEM 15 - CUSTODY
Knightsbridge does not maintain physical custody of client assets. A qualified custodian
(generally a broker-dealer, bank, trust company, insurance company, or other financial
institution) holds clients’ funds. Certain privately offered securities may qualify for an
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exemption and are held directly with the fund sponsor rather than a qualified custodian.
Knightsbridge is deemed to have custody of clients’ funds or securities in situations where
clients authorize us to instruct the custodian to deduct our advisory fees directly from the
client’s account. Knightsbridge is also deemed to have custody when clients execute a
Standing Letter of Authorization (“SLOA”) with the custodian allowing us to request
disbursements from the client’s account to payees specified in the SLOA.
Clients receive statements directly from their custodian at least quarterly. The statements
reflect the client’s funds and securities held with the custodian as well as any transactions
that occurred in the account, including the deduction of Knightsbridge’s fee. Clients should
carefully review the account statements they receive from their custodian. When clients
receive statements from Knightsbridge as well as from the custodian, clients should
compare these two reports carefully. Our statements may vary from custodial statements
based on accounting procedures, reporting dates, or valuation methodologies of certain
securities. Clients with any questions about their statements should contact us at the
address or phone number on the cover of this brochure. Clients who do not receive their
statement from the custodian at least quarterly should also notify us.
Knightsbridge does not act as custodian. However, under SEC regulations, Knightsbridge
has custody of the assets of the Fund because Knightsbridge controls the General Partner,
KAO General Partner, LLC, and is the investment manager of the Fund. Given the ability to
request funds from the custodian of the fund, Knightsbridge has established controls in
compliance with federal rules to protect clients’ assets in the Fund. A qualified custodian
holds certain of the Fund’s assets. California Carbon Allowances (“CCAs”) are custodied in
the Compliance Instrument Tracking System Service (“CITSS”), a database registry
operated and maintained by the Western Climate Initiative (“WCI”), a non-profit corporation
formed in Delaware to provide administrative and technical services to support the
implementation of state and provincial greenhouse gas emissions trading programs in
California and Quebec.
In addition, an independent accounting firm that is registered with and subject to regular
inspection by the Public Company Accounting Oversight Board (PCAOB), audits the Fund
each year with copies of the audited financial statements distributed to all investors in the
Fund within 120 days of December 31st, the end of the Fund’s fiscal year.
ITEM 16 - INVESTMENT DISCRETION
Knightsbridge has full discretion to decide the specific security to trade, the quantity, and
the timing of transactions for client accounts. Knightsbridge will not contact clients before
placing trades in their account, but clients will receive confirmations directly from the broker
for any trades placed. Clients grant us discretionary authority in the agreement they sign
with us or with their adviser (in a sub-adviser relationship), or the program sponsor (in a
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wrap fee arrangement). Clients also give us trading authority over their accounts when they
sign the custodian paperwork. Clients may revoke our discretionary authority at any time.
Certain client-imposed conditions may limit Knightsbridge’s discretionary authority, such as
where the client prohibits transactions in specific security types or directs Knightsbridge to
execute transactions through specific broker-dealers. See also Item 4 - Tailored Services
and Client Imposed Restrictions and Item – 12 Brokerage Practices, above.
In addition, on occasion we may, at our sole discretion, offer assistance to clients on a non-
discretionary basis.
ITEM 17 - VOTING CLIENT SECURITIES
Proxy Voting
Knightsbridge does not vote proxies on behalf of advisory accounts. Clients should expect
to receive proxy solicitations directly from issuers or service providers engaged on behalf
of an issuer. At the client’s request, we may offer advice regarding the exercise of client
proxy voting rights; however, clients will have the ultimate responsibility for making all
proxy-voting decisions. Knightsbridge will process corporate actions that do not require
shareholder approval, and any action taken will be in the best interest of the client. For
accounts subject to ERISA, an authorized plan fiduciary other than Knightsbridge will retain
proxy voting authority. Our investment advisory agreement and/or the plan’s written
documents will evidence and outline this authority.
Class Actions
A securities “class action” lawsuit is a civil suit brought by one or more individuals
(“Plaintiffs”) on behalf of themselves and others who have the same grievance against the
issuer of a certain security. When a class action is filed, a written notice of filing and/or
settlement is prepared (the “Notice”), which outlines the reasons for the lawsuit, the
parameters for qualification as a member of the class and certain legal rights that need to
be considered before becoming a member of the class (i.e., participating in the settlement).
In addition, the Notice will contain instructions issued by the court or broker/dealers and/or
other nominees (e.g. custodians) who receive the Notice and who hold the security on
behalf of the owner/beneficiary, to either (1) provide the Claims Administrator (usually the
attorney for the Plaintiffs) with the name and address of each such owner/beneficiary so
the Claims Administrator can send the Notice directly to such owner/beneficiary, or (2)
request additional copies of the Notice and send the Notice directly to the
owner/beneficiary. In addition to the owner/beneficiary, Knightsbridge generally also
receives notification of a class action.
In cases where Knightsbridge is responsible for filing class actions on behalf of clients, we
will first determine whether we believe that a filing is in the best interest of clients. If
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Knightsbridge deems that participation in the class action is in the best interest of the
client, Knightsbridge will complete the necessary forms and submit the claim on the client’s
behalf. In many cases, Knightsbridge can submit one claim covering all clients whose assets
are held with a particular custodian. Knightsbridge may subscribe to the services of an
unaffiliated third-party class action vendor that completes the forms and submits the
claims. Vendors are generally compensated by withholding a percentage of the award,
thereby reducing the amount received by the client.
ITEM 18 - FINANCIAL INFORMATION
Registered investment advisers are required in this item to provide clients with certain
financial information or disclosures about the firm’s financial condition if the adviser
requires the prepayment of more than $1,200 in fees per client, six months or more in
advance. Knightsbridge does not require such prepayment and does not foresee any
financial condition that is reasonably likely to impair our ability to meet contractual
commitments to clients; consequently, no additional financial disclosure is required.
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Form ADV, Part 2B Brochure Supplement
Individuals covered by this Supplement:
John G. Prichard, CFA®
Kurt E. Beimfohr
Jeffrey Vieth, CFP®
Miles E. Yourman, CFA®
Teresa A. Wagner, CFP®
Lindsey Garn Monina, CFA®
Geoffrey D. Hauck, CFA®
James R. Garrison, CFA®
Hailee Brigman
Knightsbridge Wealth Management
450 Newport Center Drive
Suite 630
Newport Beach, CA 92660
949.644.4444
www.knightsb.com
March 31, 2026
This brochure supplement provides information about John Prichard, CFA®, Kurt Beimfohr,
Jeffrey Vieth, CFP®, Miles Yourman, CFA®, Teresa Wagner, CFP®, Lindsey Garn Monina,
CFA®, Geoffrey Hauck, CFA®, James R. Garrison, CFA®, and Hailee Brigman that
supplements the Knightsbridge Wealth Management brochure. You should have already
received a copy of that brochure. Please contact us at 949.644.4444 or
knightsbridge@knightsb.com if you did not receive our brochure or if you have any
questions about the contents of this supplement.
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Additional information about John Prichard, Kurt Beimfohr, Jeffrey Vieth, Miles Yourman,
Teresa Wagner, Lindsey Garn Monina, and Geoffrey Hauck is available on the SEC’s
website at www.adviserinfo.sec.gov.
John G. Prichard, CFA®
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
President, Chief Investment Officer
Knightsbridge Wealth Management
Born: 1971
Education:
Chartered Financial Analyst®*
Boston University, MA, Finance and Banking
University of California at San Diego, BA Economics
Business Background:
1998-Present: Knightsbridge Wealth Management, Principal
1994-1998: Canterbury Capital Services, Inc., Associate
1993-1994: Santa Barbara Bank & Trust, Portfolio Administrator
*The Chartered Financial Analyst® (“CFA®”) designation is awarded by CFA Institute to individuals
who meet certain requirements. To earn a CFA charter, candidates must have four years of qualified
investment work experience, become a member of CFA Institute, pledge to adhere to the CFA
Institute Code of Ethics and Standards of Professional Conduct on an annual basis, apply for
membership to a local CFA member society, and complete the CFA Program. The CFA Program is
organized into three levels, each culminating in a six-hour exam. The three proctored course exams
correspond to three 250-hour self-study levels. Completing the Program takes most candidates
between two and five years. More information regarding the CFA is available at
https://www.cfainstitute.org.
ITEM 3 - DISCIPLINARY INFORMATION
John Prichard has no disciplinary history to disclose.
ITEM 4 - OTHER BUSINESS ACTIVITIES
John Prichard’s primary business is providing investment advice through Knightsbridge.
ITEM 5 - ADDITIONAL COMPENSATION
As a principal of Knightsbridge, John Prichard’s compensation is based on his ownership of
the firm.
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ITEM 6 - SUPERVISION
John Prichard is a Principal, President and Chief Investment Officer of Knightsbridge and is
not supervised by any other individual.
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Kurt E. Beimfohr
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Principal
Knightsbridge Wealth Management
Born: 1981
Education:
University of Virginia Darden School of Business, MBA
Claremont McKenna College, BA Economics
Business Background:
2020-Present: Knightsbridge Wealth Management, Principal
2012-2020: Buffalo Capital Corporation, President
2010-2011: Gurtin Fixed Income Management, Portfolio Management Associate
2003-2008: Pacific Investment Management Company (PIMCO), Trade Operations
ITEM 3 - DISCIPLINARY INFORMATION
Kurt Beimfohr has no disciplinary history to disclose.
ITEM 4 - OTHER BUSINESS ACTIVITIES
Kurt Beimfohr’s primary business is providing investment advice through Knightsbridge.
ITEM 5 - ADDITIONAL COMPENSATION
As a principal of Knightsbridge, Kurt Beimfohr’s compensation is based on his ownership of
the firm.
ITEM 6 - SUPERVISION
Kurt Beimfohr is a member of the investment committee which is overseen by John
Prichard, President and Chief Investment Officer. Mr. Prichard can be reached at
949.644.4444.
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Jeffrey Vieth, CFP®
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Sr. Consultant
Knightsbridge Wealth Management
Born: 1943
Education:
Certified Financial Planner CFP®*
University of California, Los Angeles, MBA
San Jose State College, BA History
Business Background:
2020-Present: Knightsbridge Wealth Management, Principal
1981-2020: Buffalo Capital Corporation, CEO and Founder
1983-1996: Titan Value Equities Group, Inc., Registered Principal
1978-Present: The Vieth Company, President
1972-Present: California Insurance License #0446429
*The Certified Financial PlannerTM certification is the standard of excellence in financial planning.
CFP® professionals meet rigorous education, training and ethical standards, and are committed to
serving their clients' best interests. Owned and awarded by the Certified Financial Planner Board of
Standards, Inc., the designation is awarded to individuals who successfully complete the CFP Board's
exam, then continue ongoing annual education programs to sustain their skills and certification.
The scope of the CFP exam includes professional conduct and regulations, financial planning
principles, education planning, risk management, insurance, investments, tax planning, retirement
planning, and estate planning. More information regarding the CFP is available at
https://www.cfp.net.
ITEM 3 - DISCIPLINARY INFORMATION
Jeffrey Vieth has no disciplinary history to disclose.
ITEM 4 - OTHER BUSINESS ACTIVITIES
Jeffrey Vieth has held a State of California Life and Health Insurance license since 1972. Mr.
Vieth is also President and owner of The Vieth Company, DBA Swiss Reserve Corporation
of America, a California Corporation, which provides contract office services to individuals
and small companies.
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ITEM 5 - ADDITIONAL COMPENSATION
Jeffrey Vieth receives compensation from the firm based on a formula related to the
number of client accounts associated with his activities. Jeff also receives commissions
from various insurance companies and agencies for insurance products. These insurance
products are neither securities nor investment products and are unrelated to the business
activities of Knightsbridge Wealth Management and are not marketed to Knightsbridge
clients.
ITEM 6 - SUPERVISION
Jeffrey Vieth serves as a consultant to Knightsbridge Wealth Management and reports to
John Prichard, President and Chief Investment Officer. Mr. Prichard can be reached at
949.644.4444.
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Miles E. Yourman, CFA®
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Principal, Portfolio Manager
Knightsbridge Wealth Management
Born: 1985
Education:
Chartered Financial Analyst®*
Columbia Business School, MBA
Dartmouth College, AB Economics
Business Background:
2015-Present: Knightsbridge Wealth Management, Principal, Portfolio Manager
2010-2015: Knightsbridge Asset Management, LLC, Research Analyst
2007-2010: Citigroup, Business Analyst
*The Chartered Financial Analyst® (“CFA®”) designation is awarded by CFA Institute to individuals
who meet certain requirements. To earn a CFA charter, candidates must have four years of qualified
investment work experience, become a member of CFA Institute, pledge to adhere to the CFA
Institute Code of Ethics and Standards of Professional Conduct on an annual basis, apply for
membership to a local CFA member society, and complete the CFA Program. The CFA Program is
organized into three levels, each culminating in a six-hour exam. The three proctored course exams
correspond to three 250-hour self-study levels. Completing the Program takes most candidates
between two and five years. More information regarding the CFA is available at
https://www.cfainstitute.org.
ITEM 3 - DISCIPLINARY INFORMATION
Miles Yourman has no disciplinary history to disclose.
ITEM 4 - OTHER BUSINESS ACTIVITIES
Miles Yourman’s primary business is providing investment advice through Knightsbridge.
ITEM 5 - ADDITIONAL COMPENSATION
As a principal of Knightsbridge, Miles Yourman’s compensation is based on his ownership
of the firm.
ITEM 6 - SUPERVISION
Miles Yourman is a member of the investment committee which is overseen by John
Prichard, President and Chief Investment Officer. Mr. Prichard can be reached at
949.644.4444.
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Knightsbridge Wealth Management
Revised March 31, 2026
Teresa A. Wagner, CFP®
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Wealth Advisor
Chief Operating Officer and Chief Compliance Officer
Knightsbridge Wealth Management
Born: 1962
Education:
Certified Financial Planner CFP®*
Registered Social Security Analyst RSSA®**
University of Phoenix, BA Management, Finance Concentration
Business Background:
2006-Present: Knightsbridge Wealth Management, COO and CCO
1995-1997: Pacific Investment Management Company (PIMCO), Vice President
1990-1995: Pacific Financial Asset Management Corporation, Director
1989-1990: Pacific Mutual Life Insurance Company, Analyst
*The Certified Financial PlannerTM certification is the standard of excellence in financial planning.
CFP® professionals meet rigorous education, training and ethical standards, and are committed to
serving their clients' best interests. Owned and awarded by the Certified Financial Planner Board of
Standards, Inc., the designation is awarded to individuals who successfully complete the CFP Board's
exam, then continue ongoing annual education programs to sustain their skills and certification.
The scope of the CFP exam includes professional conduct and regulations, financial planning
principles, education planning, risk management, insurance, investments, tax planning, retirement
planning, and estate planning. More information regarding the CFP is available at
https://www.cfp.net.
** Registered Social Security Analyst (RSSA)®
The RSSA® designation is granted by the National Association of Registered Social Security
Analysts. The designation is awarded to professionals who have demonstrated expertise in Social
Security planning and benefits optimization. The exam tested comprehension of the many facets of
Social Security as well as practical application, analyzing sample client cases. The designation
signifies a commitment to helping clients make informed decisions regarding their Social Security
benefits, with a goal of ultimately maximizing their retirement income. The RSSA® designation is an
industry-recognized credential that represents a dedication to enhancing retirement security for
clients. To maintain this designation, the RSSA® must satisfy continuing education requirements and
adhere to the RSSA® Code of Conduct.
ITEM 3 - DISCIPLINARY INFORMATION
Teresa Wagner has no disciplinary history to disclose.
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Knightsbridge Wealth Management
Revised March 31, 2026
ITEM 4 - OTHER BUSINESS ACTIVITIES
Teresa Wagner’s primary business is her employment with Knightsbridge.
ITEM 5 - ADDITIONAL COMPENSATION
Teresa Wagner’s only compensation is through her employment with Knightsbridge.
ITEM 6 - SUPERVISION
Teresa Wagner reports to Miles Yourman, Principal and Portfolio Manager, and Kurt
Beimforh, Principal. Mr. Yourman and Mr. Beimfohr can be reached at 949.644.4444.
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Knightsbridge Wealth Management
Revised March 31, 2026
Lindsey Garn (Lindsey Monina), CFA®
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Wealth Advisor
Knightsbridge Wealth Management
Born: 1993
Education:
Chartered Financial Analyst®*
Chapman University, BS Business Administration and BA Philosophy
Business Background:
2024-Present: Knightsbridge Wealth Management, Wealth Advisor
2020-2024: Pacific Life, Senior Business Strategy Analyst
2017-2020: Irvine Company, Senior Investment Analyst
*The Chartered Financial Analyst® (“CFA®”) designation is awarded by CFA Institute to individuals
who meet certain requirements. To earn a CFA charter, candidates must have four years of qualified
investment work experience, become a member of CFA Institute, pledge to adhere to the CFA
Institute Code of Ethics and Standards of Professional Conduct on an annual basis, apply for
membership to a local CFA member society, and complete the CFA Program. The CFA Program is
organized into three levels, each culminating in a six-hour exam. The three proctored course exams
correspond to three 250-hour self-study levels. Completing the Program takes most candidates
between two and five years. More information regarding the CFA is available at
https://www.cfainstitute.org.
ITEM 3 - DISCIPLINARY INFORMATION
Lindsey Garn has no disciplinary history to disclose.
ITEM 4 - OTHER BUSINESS ACTIVITIES
Lindsey Garn’s primary business is providing investment advice through Knightsbridge.
ITEM 5 - ADDITIONAL COMPENSATION
Lindsey Garn’s only compensation is through her employment with Knightsbridge.
ITEM 6 - SUPERVISION
Lindsey Garn reports to Kurt Beimfohr, Principal. Mr. Beimfohr can be reached at
949.644.4444.
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Knightsbridge Wealth Management
Revised March 31, 2026
Geoffrey D. Hauck, CFA®
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Wealth Advisor
Knightsbridge Wealth Management
Born: 1988
Education:
Chartered Financial Analyst®*
Colgate University, BA Economics and Philosophy
Business Background:
2025-Present: Knightsbridge Wealth Management, Wealth Advisor
2010-2025: Hudson Edge Investment Partners, Portfolio Manager and Senior Research
Analyst
*The Chartered Financial Analyst® (“CFA®”) designation is awarded by CFA Institute to
individuals who meet certain requirements. To earn a CFA charter, candidates must have
four years of qualified investment work experience, become a member of CFA Institute,
pledge to adhere to the CFA Institute Code of Ethics and Standards of Professional
Conduct on an annual basis, apply for membership to a local CFA member society, and
complete the CFA Program. The CFA Program is organized into three levels, each
culminating in a six-hour exam. The three proctored course exams correspond to three
250-hour self-study levels. Completing the Program takes most candidates between two
and five years. More information regarding the CFA is available at https://www.cfainstitute.org.
ITEM 3 - DISCIPLINARY INFORMATION
Geoffrey Hauck has no disciplinary history to disclose.
ITEM 4 - OTHER BUSINESS ACTIVITIES
Geoffrey Hauck’s primary business is providing investment advice through Knightsbridge.
ITEM 5 - ADDITIONAL COMPENSATION
Geoffrey Hauck’s only compensation is through his employment with Knightsbridge.
ITEM 6 - SUPERVISION
Geoffrey Hauck reports to Kurt Beimfohr, Principal. Mr. Beimfohr can be reached at
949.644.4444.
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Knightsbridge Wealth Management
Revised March 31, 2026
James R. Garrison, CFA®
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Wealth Advisor
Knightsbridge Wealth Management
Born: 1975
Education:
Chartered Financial Analyst®*
University of California, Davis, BA in Agricultural and Managerial Economics
Business Background:
2025-Present: Knightsbridge Wealth Management, Wealth Advisor
1999-2025: First Foundation Advisors, Portfolio Manager and Research Analyst
*The Chartered Financial Analyst® (“CFA®”) designation is awarded by CFA Institute to
individuals who meet certain requirements. To earn a CFA charter, candidates must have
four years of qualified investment work experience, become a member of CFA Institute,
pledge to adhere to the CFA Institute Code of Ethics and Standards of Professional
Conduct on an annual basis, apply for membership to a local CFA member society, and
complete the CFA Program. The CFA Program is organized into three levels, each
culminating in a six-hour exam. The three proctored course exams correspond to three
250-hour self-study levels. Completing the Program takes most candidates between two
and five years. More information regarding the CFA is available at https://www.cfainstitute.org.
ITEM 3 - DISCIPLINARY INFORMATION
James Garrison has no disciplinary history to disclose.
ITEM 4 - OTHER BUSINESS ACTIVITIES
James Garrison’s primary business is providing investment advice through Knightsbridge.
ITEM 5 - ADDITIONAL COMPENSATION
James Garrison’s only compensation is through his employment with Knightsbridge.
ITEM 6 - SUPERVISION
James Garrison reports to Kurt Beimfohr, Principal. Mr. Beimfohr can be reached at
949.644.4444.
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Knightsbridge Wealth Management
Revised March 31, 2026
Hailee Brigman
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Sr. CSA and 401K Specialist
Knightsbridge Wealth Management
Born: 1998
Education:
California State University, Long Beach, BA in Mathematical Economics and Economic
Theory
Business Background:
2023-Present: Knightsbridge Wealth Advisor, Sr. Client Service Associate and 401K
Specialist
2019-2023: Morgan Stanley, Reporting Analyst and Registered Client Service Associate
ITEM 3 - DISCIPLINARY INFORMATION
Hailee Brigman has no disciplinary history to disclose.
ITEM 4 - OTHER BUSINESS ACTIVITIES
Hailee Brigman primary business is serving clients and providing financial planning advice
through Knightsbridge.
ITEM 5 - ADDITIONAL COMPENSATION
Hailee Brigman only compensation is through his employment with Knightsbridge.
ITEM 6 - SUPERVISION
Hailee Brigman reports to Kurt Beimfohr, Principal, and Miles Yourman, Principal and
Portfolio Manager. Mr. Beimfohr and Mr. Yourman can be reached at 949.644.4444.
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Knightsbridge Wealth Management
Revised March 31, 2026
Knightsbridge Wealth Management
PRIVACY NOTICE
Consistent with the Securities and Exchange Commission adoption of Regulation S-P, the
Gramm-Leach-Bliley Act, which restricts the disclosure of “non-public personal information”
pertaining to consumers (customers or clients) by financial institutions, the following
pertains.
Knightsbridge Asset Management, LLC, DBA Knightsbridge Wealth Management
(“Knightsbridge”) may collect non-public information pertaining to clients from various
sources in the process of managing client portfolios. Knightsbridge may collect the
following kinds of confidential personal information about clients: 1) information we receive
from the client on applications or other forms, such as name, address, phone number, social
security number, occupation, assets, income and other financial and family information; 2)
information about the client’s transactions with us or with brokerages, banks and
custodians with whom the client holds investment or cash accounts, including account
numbers, holdings, balances, transaction history and other financial and investment
activities. We may receive this information from the client and/or a third-party through
various agreements, applications, and other documents, as a result of client security
transactions or as information divulged orally. All non-public information pertaining to
clients, regardless of source, will be treated confidentially.
Knightsbridge does not sell or disclose any non-public information regarding current or
former clients without client authorization, except as permitted by law or in direct response
to inquiries from governmental authorities. Information may also be disclosed to unaffiliated
third parties (such as custodians, brokers, accountants, pension administrators or
attorneys) when requested by the client or as required or permitted by law and only as
needed in the discharge of our professional duties and service to clients.
Knightsbridge restricts access to a client’s non-public personal information to those
employees who need to know that information to provide products or services to the client.
Knightsbridge maintains physical, electronic, and procedural safeguards to guard client’s
non-public personal information.
If, at any time in the future, it is necessary to disclose a client’s personal information in a
way that differs with this policy, we will provide advance notice of the proposed change and
the opportunity to opt out of such disclosure.
If you have any questions about the contents of this privacy notice, please contact us at
949.644.4444 or knightsbridge@knightsb.com
39
Primary Brochure: KNIGHTSBRIDGE WEALTH MANAGEMENT FORM ADV, PART 2A WRAP BROCHURE (2026-03-31)
View Document Text
450 Newport Center Drive
Suite 630
Newport Beach, CA 92660
949.644.4444
www.knightsb.com
Form ADV, Part 2A Appendix 1
Wrap Fee Program Brochure
March 31, 2026
of
this
brochure,
please
contact
us
at
949.644.4444
This wrap fee program brochure provides information about the qualifications and business
practices of Knightsbridge Asset Management, LLC, DBA Knightsbridge Wealth
Management (hereafter referred to as “Knightsbridge”). If you have any questions about the
contents
or
knightsbridge@knightsb.com. The information in this brochure has not been approved or
verified by the United States Securities and Exchange Commission or by any state securities
authority.
Any reference to or use of the terms “registered investment adviser” or “registered,” does
not imply that Knightsbridge Asset Management, LLC or any person associated with
Knightsbridge Asset Management, LLC has achieved a certain level of skill or training.
information about Knightsbridge
is available on the SEC’s website at
Additional
www.adviserinfo.sec.gov.
ITEM 2 - MATERIAL CHANGES
Revised March 31, 2026
Knightsbridge reviews and updates Form ADV at least annually to confirm that it remains
current.
The purpose of this page is to inform you of any material changes since the last update to
this brochure. If you are receiving this brochure for the first time, this section may not be
relevant to you.
No material changes were made since the last update to Knightsbridge’s brochure dated
March 28, 2025.
Our complete Form ADV Part 2A & 2B may be requested by contacting our firm at 949.
644.4444 or by email at knightsbridge@knightsb.com.
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ITEM 3 - TABLE OF CONTENTS
ITEM 2 - MATERIAL CHANGES ........................................................................................................... 2
ITEM 3 - TABLE OF CONTENTS ......................................................................................................... 3
ITEM 4 - SERVICES, FEES AND COMPENSATION........................................................................ 4
ITEM 5 - ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ............................................. 6
ITEM 6 - PORTFOLIO MANAGER SELECTION AND EVALUATION.......................................... 7
ITEM 7 - CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS........................ 13
ITEM 8 - CLIENT CONTACT WITH PORTFOLIO MANAGERS.................................................. 13
ITEM 9 - ADDITIONAL INFORMATION............................................................................................ 13
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Knightsbridge Wealth Management
ITEM 4 - SERVICES, FEES AND COMPENSATION
Knightsbridge is an independent, 100% employee-owned limited liability company
headquartered in Newport Beach, California. Knightsbridge is registered as an investment
adviser with the U.S. Securities and Exchange Commission.
Knightsbridge was co-founded in 1998 by John Prichard, CFA. Historical investment results
include periods under predecessor firms Canterbury Capital Services, Inc. (1992) and
Buffalo Capital Corporation (1993). John Prichard, CFA, Kurt Beimfohr, and Miles Yourman,
CFA currently own the firm.
Knightsbridge Wrap Fee Program
Knightsbridge provides investment advisory services directly to retail clients through a wrap
fee program, as described in this brochure. Knightsbridge is both the sponsor and currently
the only portfolio manager for our wrap fee program. Knightsbridge no longer offers this
program to new investors.
Client investments may include over the counter and exchange-traded securities such as
common and preferred stocks and bonds, American Depository Receipts (ADRs), foreign
securities listed on foreign exchanges (ordinaries), Real Estate Investment Trusts (REITs),
closed-end and open-end mutual funds, exchange-traded funds (ETFs), interests in
exchange-traded and private limited partnerships or funds that may be illiquid, fixed income
securities such as corporate, mortgage, government and municipal bonds, and floating rate
notes. Accounts may at times hold material positions in cash or cash equivalents.
Fees for the Program
Clients participating in our wrap fee program pay a single bundled fee to Knightsbridge for
our advisory services and commissions on transactions instead of paying these fees
separately. The maximum annual fee charged is 1.5%. The specific advisory fees are set
forth in your Investment Management Agreement.
Additional fees charged to clients of the Knightsbridge wrap fee program may include wire
fees, and other fees and taxes on brokerage accounts and securities transactions including
possible SEC transaction fees, postage, handling or other miscellaneous transaction
related costs. Clients may also incur charges imposed by closed-end and open-end mutual
funds and exchange-traded funds which are disclosed in the fund’s prospectus (i.e., fund
management fees, operating expenses, or variable annuity fees). Clients in the program
ultimately bear these costs in addition to the wrap fees charged directly to the client.
Participating in the wrap fee program may cost a client more or less than purchasing
investment management and trading services separately. Factors that may affect the cost
of a wrap fee program relative to other compensation arrangements include: the advisory
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Revised March 31, 2026
Knightsbridge Wealth Management
fees the client would pay for Knightsbridge’s investment management services if the fees
were un-bundled; the transaction and execution fees the custodian would charge to the
client under a non-wrap fee arrangement, and the frequency and volume of trading activity
in the client’s account. Under the terms of this wrap fee program, Knightsbridge will pay
trading and execution costs imposed by the custodian for transactions in client accounts.
This arrangement presents a conflict of interest for Knightsbridge, as Knightsbridge has a
financial disincentive to engage in active trading. However, transaction fees are not a
material consideration for Knightsbridge in deciding whether to engage in any trading or the
level of trading activity through the custodian. We make investment decisions for clients in
wrap fee programs the same way we manage accounts where the client pays for trading
and execution costs separately.
Knightsbridge receives compensation when clients participate in this wrap fee program.
This compensation may be more than what Knightsbridge would receive if clients
participated in other programs at Knightsbridge or paid separately for investment advice,
brokerage, and other services, and Knightsbridge may therefore have a financial incentive
to recommend the wrap fee program over other programs or services.
In addition to Knightsbridge’s investment advisory fee and other such fees, Clients in a
Personalized Equity Indexing strategy may also pay all margin interest and fees, and/or
other similar charges incurred in connection with transactions in accounts, from the assets
in the account. Such fees include all brokerage commission costs for securities
transactions affected for the Client’s account. Any fees described as
Registration/Handling/Postage/Transfer Fees or fees imposed by the Securities and
Exchange Commission shall be borne by the client account. In addition, if a client agrees to
use margin to purchase assets that an unaffiliated third party will manage as part of the
Personalized Equity Indexing strategy, Knightsbridge will include the entire market value of
the margined assets when computing its advisory fee. As part of the Personalized Equity
Indexing strategy, Clients will pay a separate and additional investment advisory fee under
an Investment Advisory Agreement to an unaffiliated third-party sub-adviser.
Billing Method
All separate accounts controlled by a single client under the wrap fee program will be taken
together as if one account for purposes of determining fees. Once the client reaches a
breakpoint, Knightsbridge bills all assets under management in the portfolio at the lower
rate.
Fees will be charged quarterly in arrears. Fees are calculated quarterly based on the
portfolio value of the client’s assets under management, including accrued interest, at the
close of business on the last day of each calendar quarter. All assets in any form in the
client’s account are considered in determining the portfolio value, including cash balances,
money market assets, equity and debt positions.
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Revised March 31, 2026
Knightsbridge Wealth Management
Knightsbridge does not charge fees for the initial quarter after inception of the account if
we manage the account for less than a full calendar quarter. Fees are due no later than 30
days after the calendar quarter.
With client authorization, Knightsbridge will instruct the custodian to automatically withdraw
its advisory fee from the client’s account on a quarterly basis. The quarterly reports we
send to clients will show the amount of the fee and the fee calculation. Knightsbridge may
accommodate client requests to be billed directly.
All clients will receive brokerage statements from the custodian no less frequently than
quarterly. The custodian statement will show the deduction of the advisory fee. It is the
client’s responsibility to verify the accuracy of the fee calculation. The custodian will not
determine whether the fee is properly calculated.
Termination of Agreements
Either party may terminate the agreement upon ten (10) days written notice to the other
party; however, the client can revoke our discretionary authority over the account at any
time. The client will be responsible for paying fees for services through the effective date of
termination. Clients may terminate the agreement by writing Knightsbridge at our office.
Any notice shall be deemed effective upon actual receipt of written acknowledgement.
Upon notice of termination, Knightsbridge will calculate the final fees due for services
provided through the date of termination. Any advisory fees earned for services provided
will be due upon termination. We will prorate the fee due based on the effective date of
termination.
ITEM 5 - ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS
Clients in Knightsbridge’s wrap fee program may include retail clients such as individuals,
high net worth individuals, trusts and estates, individual participants of retirement plans,
pension and profit-sharing plans, charitable organizations, and businesses. Knightsbridge
also offers advisory services to institutional clients.
Account Requirements
Generally, Knightsbridge requires a minimum account size of $500,000 for accounts in our
wrap fee program. We may combine family accounts to meet the account size minimum.
Knightsbridge may reduce or waive the account minimum requirements at its discretion.
Knightsbridge may recommend that qualified clients participate in securities lending
programs offered by their custodians.
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Knightsbridge Wealth Management
ITEM 6 - PORTFOLIO MANAGER SELECTION AND EVALUATION
Portfolio Management and Performance Calculation
Knightsbridge is the sponsor and currently the only portfolio manager of our wrap fee
program.
Advisory Business
Investment Advisory Services Offered
Knightsbridge offers investment advisory services directly to retail and institutional clients
in individually managed accounts, to clients referred by solicitors, and through sub-advisory
and wrap-fee arrangements. This wrap fee program brochure describes the services we
provide to clients of the Knightsbridge wrap fee program and our investment and trading
policies as they relate to wrap fee program clients. The other services Knightsbridge offers
are described in more detail in our Form ADV Part 2A brochure, which is available upon
request.
Tailored Services and Client Imposed Restrictions
Knightsbridge manages client accounts based on the investment strategy the client
chooses, as discussed below under Methods of Analysis, Investment Strategies, and Risk
of Loss.
Clients may request restrictions on their account, such as a minimum level of cash or
avoidance of specific securities or security types. Any such limitation may add client-
imposed risk of loss and reduction of investment return. It is the client’s responsibility to
keep Knightsbridge informed of any changes to their investment objectives or restrictions.
Other Wrap Fee Programs
In addition to sponsoring our own wrap fee program, Knightsbridge manages accounts in
wrap fee programs sponsored by other financial services firms. The company sponsoring
the program pays Knightsbridge a portion of the wrap fee for investment management
services as portfolio manager.
Knightsbridge chooses investments for clients in wrap fee programs the same way we
make investment decisions for other client accounts.
Performance-Based Fees and Side-by-Side Management
Knightsbridge typically charges asset-based fees for its investment management services.
Knightsbridge has also negotiated with certain clients a performance-based incentive fee.
We may only offer performance-fee arrangements to clients that meet certain internal and
regulatory qualifications. Specifically, clients meeting assets under management or net
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Revised March 31, 2026
Knightsbridge Wealth Management
worth tests of SEC Rule 205-3 under the Investment Advisers Act of 1940 may elect to
have assets managed by the firm on a performance compensation basis.
Knightsbridge may give advice to or take action for performance-based incentive fee
accounts that differs from advice given to or action taken for other managed accounts as
the investment objectives and risk tolerance for these accounts differ from other managed
accounts.
These arrangements create a conflict of interest for Knightsbridge as it creates an
incentive to allocate investment opportunities that it believes might be the most profitable
to accounts charged performance-based or higher asset-based fees.
Knightsbridge has adopted policies and procedures reasonably designed to allocate
investment opportunities between accounts on a fair and equitable basis over time and
prevent non-suitable investments in client accounts.
Methods of Analysis, Investment Strategies and Risk of Loss
Investment Philosophy
Knightsbridge focuses on building low cost, tax-efficient investment portfolios. With all
strategies, we seek to deliver attractive risk-adjusted returns. We also employ active risk
management in many of our strategies. As such, cash equivalents, sometimes used as a
defensive tool, may at times represent a significant portion of the client’s account, including
up to 100% of our Managed Income strategy.
Investment Strategies
Knightsbridge offers the following strategies:
Opportunistic Value Equity strategy: A growth-oriented active equity strategy
For investors seeking capital appreciation. We attempt generate strong returns by
investing among stocks exhibiting either a “structural investment anomaly” which may be
temporarily depressing price or a “signaling investment anomaly” indicating undervaluation
compared to intrinsic value. We also like to have the following qualities present:
manageable debt load; cash generative business; good returns on capital; alignment of
management; revenue growth.
Long Term Quality Equity strategy: A tax-optimized active equity strategy
For investors seeking long-term growth who benefit from deference of tax realization. We
invest in quality companies capable of ‘compounding’ tax efficiently over a holding period of
many years. We define a quality company as one which possesses: consistency in
profitability; good returns on capital; no major secular pressures; little risk of obsolescence;
easily manageable debt. With higher quality companies, we invest where valuations allow
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Revised March 31, 2026
Knightsbridge Wealth Management
for adequate absolute returns. A reasonable starting valuation allows business cash flows,
not perceptions, to ultimately drive investment results. We do not stretch for rock-bottom
valuations that are often warning signs of business deterioration and we avoid excessively
levered companies.
Managed Income: An actively managed fixed income strategy
For conservative investors seeking daily liquidity and more consistent positive returns. Our
Managed Income strategy targets a positive total return during all one-year periods through
active risk management with an emphasis on fixed income securities. Investors in our
Managed Income strategy should experience low downside principal volatility.
Balanced: includes allocation to both equity and fixed income strategies
Balanced portfolios blend varying degrees of equity and fixed income exposure, utilizing the
above strategies, to tailor the level of risk and potential return to meet each individual
client’s objectives. Our Tax Optimized Balanced Strategy is employed for taxable accounts.
Investments will vary depending on clients’ tax brackets. Our Tax Agnostic Balanced
Strategy is employed for non-taxable accounts.
Personalized Equity Indexing: Includes allocation to equities, including those potentially
bought on margin or a short position. Depending on the tax loss harvesting strategy
employed, investors either get straight equity exposure with or without factor tilts, or with
specific tilts designed by the subadvisor intended to generate alpha as well as beta. The
subadvisors generally tax-harvest positions that lose value below their basis and thus allow
for the cumulation of taxable losses while the other positions perform to the market plus or
minus any alpha.
Methods of Analysis
Our portfolio management incorporates strategic and tactical asset allocation and applies
both fundamental and technical research and analysis. In addition to our own internal
research and analysis, we receive research and analysis from external sources including
brokerage firms and mutual fund companies. Some of this research and analysis is
available at no cost, others we purchase.
Step One: Objective Setting
We seek to obtain a clear understanding of the client’s investment goals based on the
client’s expectations and time horizon, as well as the client’s ability and willingness to
assume risk. We use this information to establish an appropriate portfolio strategy
consistent with the client’s investment objectives.
Step Two: Asset Allocation
Our asset allocation process begins with our assessment of the impact of various factors
such as economic indicators, monetary policy and political developments on the financial
markets. We then implement a portfolio strategy that is consistent with the client’s goals
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Knightsbridge Wealth Management
and objectives by deploying assets across equity (stocks), fixed income (bonds) and other
asset classes (cash, gold, commodities, etc.).
Step 3: Sector Allocation
Sector selection adds further diversification to the portfolio matrix by allocating across a
variety of sectors which may or may not include large, mid or small cap, value or growth
equity stocks and funds, as well as various fixed income classes, such as corporate (both
investment grade and below investment grade), government (Treasury, agency, municipal),
mortgage and asset backed.
Step 4: Investment Selection
Fund Selection: While we primarily select funds with a demonstrated track record of
consistently superior returns, it is important to look beyond historical performance and
understand the characteristics of each fund. For active funds, we regularly conduct internal
research to ensure we have a thorough understanding of fund investment style. For
passive funds, we regularly monitor fees and tracking error.
Stock Selection: When investing in stocks in taxable accounts, we generally invest for the
long-term, in quality businesses, seeking an adequate absolute return in a tax efficient
manner. We define a quality company as having: consistent profitability; decent returns on
capital; no major secular pressures; little risk of obsolescence; easily manageable debt.
When investing in stocks in tax-exempt accounts, we generally invest among stocks
exhibiting “investment anomalies” and/or where our analysis indicates intrinsic value in
excess of current stock price.
Fixed Income Selection: In evaluating fixed income securities for balanced accounts,
Knightsbridge considers the financial strength of the issuer, call provisions, liquidity factors,
credit spreads, and bond insurance in selecting bonds for purchase. Knightsbridge relies on
credit rating agencies such as Standard & Poor’s and Moody’s to help determine the
financial strength of issuing creditors. We also use prospectuses, other relevant information
from bond underwriters, and/or sources of market data to help in analysis and selection of
fixed income securities. Knightsbridge may solicit bids from several sources to obtain the
most attractive price/yield on purchase or sale.
Step 5: Portfolio Review Process
The portfolio review process consists of the daily monitoring of the stock and bond markets
and based on our models, the increase or reduction of the client’s equity and/or fixed
income assets. In addition, sector allocations are changed based upon our forward-looking
assessment of investment risks and opportunities within the current economic cycle.
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Investing Involves Risks
All investment programs have certain risks that are borne by the investor, including the risk
that an investor may lose part or all his or her investment. Past performance is not
indicative of future results; therefore, investors should not assume future performance will
be profitable.
Prior to entering into an agreement with Knightsbridge, the client should carefully consider:
Investing in securities involves risk of loss which clients should be prepared to bear;
1.
2. Securities markets experience varying degrees of volatility;
3. Certain securities may be illiquid;
4. Account values will fluctuate and at any time be worth more or less than the amount
invested;
5. Clients should only commit assets available for investment on a long-term basis;
6. Accounts may hold a limited number of individual stocks, i.e. potentially 15 or fewer,
in which case diversification would be limited.
7. Accounts may hold high levels of cash at times, potentially up to 100%. This induces
timing risk and the potential to miss out on investment gains.
8. Accounts may not be fully invested at inception. This induces timing risk and the
potential to miss out on investment gains.
9. Knightsbridge may trade outside of normal stock market hours. Trading before or
after these hours; there are no guarantees that we will obtain the price we want or
that the order will fill at all.
Investors should be aware that accounts are subject to the following risks:
Specific Security Risks: Knightsbridge generally seeks investment strategies that do not
involve significant or unusual risk beyond that of the general domestic and/or international
equity and fixed income markets. Other strategies such as using margin or leverage can be
used when Client’s utilize an unaffiliated third-party as part of a Personalized Equity
Indexing strategies, or Knightsbridge deems it appropriate for a particular account or given
market condition. While the use of margin borrowing or leveraged funds can increase
returns, it can also magnify losses in the event of a significant downturn in the market.
Clients are responsible for the payment of any margin charges. These specific strategies
can increase risks independent of the many risks inherent to investing. Investing in
securities involves risk of loss that Clients should be prepared to bear. Securities markets
experience significant degrees of volatility. Over time, a Client’s assets may fluctuate and at
any time be worth more or less than the amount invested.
Market Risk: The price of a stock, bond, mutual fund, ETF or other security may drop in
reaction to tangible and intangible events and conditions. This type of risk is caused by
external factors independent of a security’s underlying circumstance.
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Foreign Risk: Investments in international securities include exposure to risks such as
currency fluctuations, foreign taxes and regulations, and political instability.
Capitalization Risk: Younger and smaller companies may be hindered as a result of limited
resources or less diverse products or services, resulting in more volatility than larger, more
established companies.
Interest Rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate.
For example, when interest rates rise, yields on existing bonds become less attractive,
causing their market values to decline. Declining interest rates increase reinvestment and
call risk, whereby interest income and return of principal would be invested at lower
prevailing rates. In low interest rate environments, advisory fees may exceed cash yields.
Legal/Regulatory Risk: Certain investments or issuers of investments may be affected by
changes in state or federal laws, tax laws, or in the prevailing regulatory framework under
which the investment or issuer is regulated, negatively impacting the overall performance of
such investments.
Credit Risk: The issuer of a security may be unable to make interest or dividend payments
and/or repay principal when due. A downgrade to an issuer’s credit rating or a perceived
change in an issuer’s financial strength may negatively affect a security’s value.
Liquidity Risk: Certain assets may not be readily converted into cash or may have a limited
market in which they trade, resulting in unfavorable pricing when selling. Private
partnerships or funds may significantly restrict the ability to redeem funds. Limitations may
include a waiting period before initial redemption, periodic redemptions which require
advance notice, acceptance of only a portion of requested redemption, and other
restrictions which limit control on the timing and amount of redemption. Knightsbridge is
not responsible for, and bears no liability associated with, such limitations.
Inflation Risk: Purchasing power erodes at the rate of inflation, so the value of investments
in the future may not be worth what they are today.
Cybersecurity Risk: Investment advisers, including Knightsbridge, must rely in part on
network technologies to conduct their businesses. Such networks may be at risk of
unauthorized access for purposes of misappropriating sensitive information, corrupting
data, or causing operational disruption. Knightsbridge has established a business continuity
plan intended to reduce such risks and safeguard our data; nevertheless, cyber incidents
could potentially occur.
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Voting Client Securities
Proxy Voting
Knightsbridge does not vote proxies on behalf of advisory accounts. Clients should expect
to receive proxy solicitations directly from issuers or service providers engaged on behalf
of an issuer. At the client’s request, we may offer advice regarding the exercise of client
proxy voting rights; however, clients will have the ultimate responsibility for making all
proxy-voting decisions. Knightsbridge will process corporate actions that do not require
shareholder approval, and any action taken will be in the best interest of the client.
ITEM 7 - CLIENT INFORMATION PROVIDED TO PORTFOLIO
MANAGERS
Knightsbridge collects information from clients about their financial situation, goals, and risk
tolerance. Clients are encouraged to contact Knightsbridge whenever this information
changes.
ITEM 8 - CLIENT CONTACT WITH PORTFOLIO MANAGERS
We have no restrictions on clients’ ability to contact and consult with Knightsbridge.
ITEM 9 - ADDITIONAL INFORMATION
Disciplinary Information
Knightsbridge and its personnel seek to maintain the highest level of professionalism,
integrity, and ethics. Knightsbridge does not have any disciplinary information to disclose.
The firm and all its past and current principals have never been sued or sanctioned by the
Securities and Exchange Commission (“SEC”).
Other Financial Industry Activities and Affiliations
Knightsbridge is the investment manager to KWM Asymmetric Opportunities Fund, LP, a
private fund (the “Fund”). KAO General Partner, LLC, a California limited liability company
and, serves as the general partner (the “GP” or General Partner”) of the Fund.
Knightsbridge is the sole member of the GP and the owners of Knightsbridge are also the
Managing Members of the GP. The GP has delegated the investment management
responsibilities for the Fund to Knightsbridge. The Fund is a Delaware limited partnership
and is not publicly offered or traded. The Fund is only available to “accredited investors” as
the term is defined by Rule 501(a) of Regulation D of the Securities Act of 1933. The Fund’s
offering documents provide additional information on these standards. Prospective
investors in the Fund receive the offering documents. This Form ADV Part 2A Appendix 1
Wrap Fee Brochure is not an offer to sell, or a solicitation of an offer to purchase,
membership interests in the Fund. Such an offer can only occur when the prospective
investor receives the offering documents.
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Additional information regarding Knightsbridge’s other services, including the Fund, and any
related conflicts are described in more detail in our Form ADV Part 2A brochure, which is
available upon request. See also Code of Ethics below.
Codes of Ethics, Participation or Interest in Client Transactions and Personal
Trading
Code of Ethics
Knightsbridge owes clients the highest level of trust and fair dealing. As part of our fiduciary
duty, we place the interests of clients ahead of the interests of the firm and our personnel.
We have adopted a Code of Ethics that emphasizes the high standards of conduct that
Knightsbridge seeks to observe. Knightsbridge personnel are required to conduct
themselves with integrity at all times and follow the principles and policies detailed in our
Code of Ethics.
Knightsbridge’s Code of Ethics addresses specific conflicts of interest that could likely
arise. Knightsbridge personnel are required to follow clear guidelines from the Code of
Ethics in areas such as gifts and entertainment, other business activities, and adherence to
applicable federal securities laws.
Knightsbridge will provide a complete copy of the Code of Ethics to any client or
prospective client upon request.
Personal Trading Practices
Knightsbridge personnel are subject to personal trading policies governed by the Code of
Ethics. Personnel may trade the same securities recommended to clients. Personal trading
presents a potential conflict of interest as there is potential to favor our personal accounts
over client accounts when allocating trades or trade ahead of clients.
Our policies to address these conflicts include the following:
1. We seek to always put the best interests of clients first and to never place our
interests ahead of clients.
2. We prohibit trading in any manner that takes advantage of our knowledge of client
transactions.
3. Knightsbridge personnel must request pre-clearance from our Chief Compliance
Officer if they wish to purchase or sell a security that is commonly owned by clients,
that is being considered for purchase or sale, IPOs, limited offerings, private
placements or public or private offerings of interests in limited partnerships or any
thinly traded securities. Direct obligations of the U.S. government, some short-term
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debt securities and CDs, money market funds and mutual funds do not need to be
pre-cleared.
4. Knightsbridge employs a trade rotation policy. Trades of our personnel are always
placed last in the rotation. We may however execute client and employee accounts
together in the same custodial block. Trade execution prices received by personnel
versus clients will vary depending upon timing of execution.
5. These policies are intended to protect the interests of clients. We may make
exceptions where we feel clients would not be harmed, and in certain strategies due
to overall liquidity and trading management.
Participation or Interest in Client Transactions
A client may need to sell a security that we think is a good fit for another client’s account. In
this case, we may internally cross the security from the selling client to the buying client’s
account, if in the best interests of both clients. Usually, this situation arises with fixed
income securities where both clients benefit through better pricing by crossing the security
instead of going into the open market to complete separate transactions.
All internal cross transactions will be priced at the independent current market price of the
security. We will also consider any additional fees charged by the broker/custodian.
Cross trades are an exception to Knightsbridge’s normal operating procedures and will only
be affected when it is of conspicuous advantage to both accounts in the absence of
appropriate and comparable alternatives.
Private Fund Interests
Knightsbridge is the investment manager to KWM Asymmetric Opportunities Fund, LP, a
private fund (the “Fund”). KAO General Partner, LLC, a California limited liability company and
related person of Knightsbridge, serves as the general partner (the “GP” or General Partner”)
of the Fund. Some of our advisory clients are also investors in the Fund. Because
Knightsbridge has an interest in the Fund, we benefit when we recommend that clients invest
in the Fund. To address this conflict of interest, Knightsbridge only offers the Fund interests to
clients who meet the requisite income and/or net worth requirements and where we believe
that the investment is appropriate for the client based on the client’s ability to accept the risk.
Clients will receive the offering documents and full disclosure of known risks before investing.
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Brokerage Practices
The Custodians We Use
Knightsbridge does not maintain custody of your assets, although we may be deemed to
have custody of your assets if you give us authority to withdraw assets from your account.
Your assets must be maintained in an account at a “qualified custodian,” generally a broker-
dealer or bank, and you open an account by entering into an account agreement directly
with them. Certain privately offered securities may qualify for an exemption and are held
directly with the fund sponsor rather than a qualified custodian. Knightsbridge may provide
the names of certain custodians as options for a client to consider, typically Fidelity
Investments (“Fidelity”) and Charles Schwab & Co., Inc. (“Schwab”) and may assist you in
opening an account. Knightsbridge is independently owned and operated and is not
affiliated with Fidelity or Schwab. These custodians hold your assets in a brokerage
account and buy and sell securities at our instruction. Conflicts of interest associated with
these arrangements are described below as well as in Client Referrals and Other
Compensation.
Factors Considered in Selecting Broker-Dealers for Client Transactions
When determining the terms that a custodian/broker provides are advantageous when
compared with other available providers, we take into account a wide range of factors,
including:
• Transaction execution services and asset custody services (generally without a
separate fee for custody)
• Capability to execute, clear, and settle trades (buy and sell securities for your
account)
• Capability to facilitate transfers and payments to and from accounts (wire transfers,
check requests, electronic fund transfers, etc.)
• Breadth of available investment products (stocks, bonds, mutual funds, exchange-
trades funds, etc.)
• Availability of investment research and tools that assist us in making investment
decisions
• Quality of services
• Competitiveness of the price of those services (commission rates, other fees, etc.)
• Reputation, financial strength, security and stability
• Prior service to us and our clients
• Availability of other products and services that benefit us, as discussed below
Fidelity and Schwab do not generally charge for custody services. They are compensated
by other fees such as commissions or other fees on trades they execute or settle into your
account, earned interest on the uninvested cash in your account, and “prime broker” or
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“trade away” fees for trades executed by a different broker-dealer and are settled into your
account. To minimize your trading costs, we “trade away” only when we determine it is in
your best interest.
Fidelity and Schwab may provide products and services that benefit us but do not directly
benefit you or your account. These products and services assist us in managing and
administering our clients’ accounts and generally include investment research, software and
other technology that provide access to client account data, trade execution and allocation,
and pricing and market data. Fidelity and Schwab may also offer other services intended to
help us manage and further develop our business enterprise, such as educational
conferences and publications on practice management. These services can create a
conflict of interest because they are an incentive for us to recommend Fidelity or Schwab.
However, we believe such a recommendation is supported by the scope, quality, and price
of services and therefore in the best interests of our clients.
Aggregation and Allocation of Transactions
Knightsbridge may aggregate orders for clients in the same securities in an effort to seek
best execution, negotiate more favorable commission rates, and/or allocate differences in
prices equitably among our clients.
Based on our management process and the investments we recommend, there may be
times where we cannot or choose not to aggregate client trades or where trading
opportunity for a particular security is limited. Knightsbridge may choose not to implement
or aggregate a trade order across all accounts if, in our view, it would not be in the best
interest of certain clients. For example, a trade might not be allocated to an account with
client-imposed restrictions or which lacks adequate funds available for an investment. In all
circumstances, Knightsbridge attempts in good faith to allocate trades and investment
opportunities among clients in a manner that, over time, is equitable to all our clients.
When aggregating orders and placing trades, Knightsbridge will observe the following
procedures:
1. We will only aggregate trades when consistent with our duty to seek best execution
for our clients.
2. No client account will be favored over any other client account within a trading block.
3. Each account that participates in an aggregated transaction will participate at the
average of the executed share price for that transaction.
4. Knightsbridge employs a trade rotation policy. Trades of our personnel are always
placed last in the rotation. We may however execute client and employee accounts
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together in the same custodial block. Overall liquidity and trading management of
certain strategies are an exception to this policy. Trade execution prices received by
personnel versus clients will vary depending upon timing of execution.
5. Trades are allocated/created at the account level and then aggregated into a block
before an order is transmitted to a broker for execution (Pre-Allocation Order). In
rare circumstances where timing is critical and we determine it would be in clients’
best interests to promptly begin trading, we may transact in a security without a Pre-
Allocation Order. In such circumstances, allocations will be determined within four
hours of beginning the trading exercise.
6. If the aggregated transaction is filled entirely, it will be allocated among the accounts
listed on the Pre-Allocation Order. If the order is partially filled, we will typically
allocate on a random basis. Overall liquidity and trading management of certain
strategies are an exception to this policy and will be allocated proportionately.
7.
In particular circumstances, we may allocate on a pro-rata basis according to the
following methods:
a. When only a small percentage of the order is executed, with respect to
purchase allocations, allocations may be given to accounts high in cash;
b. With respect to sale allocations, allocations may be given to accounts low in
cash;
c. We may allocate shares to the account with the smallest order, or to the
smallest position, or to an account that is out of line with respect to security
or sector weightings, relative to other portfolios with similar mandates;
d. We may allocate to an account with investment guidelines prohibiting
e.
purchase of other securities;
If an account reaches an investment guideline limit and cannot participate in
an allocation, we may reallocate shares to other accounts. For example, this
may be due to unforeseen changes in an account’s assets after an order is
placed.
We will document the reasons for any deviation from a random allocation.
Review of Accounts
Account Reviews
Knightsbridge manages portfolios through a continuous review process (tactical allocation)
plus a regular periodic review process (strategic allocation). These portfolio reviews are
conducted by an officer of the firm.
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The continuous review process consists of the daily monitoring of the stock and bond
markets, our analysis of the economic climate and the signals provided by tactical decision
models. Reviews may result in the increase or reduction of the clients’ equity and/or fixed
income allocation.
All accounts are reviewed on a timely basis to verify the accuracy of individual account
transactions at the time a transaction is made. These transaction reviews are conducted by
administrative personnel under the direct supervision of an officer of Knightsbridge.
Account Reporting
On a quarterly basis, clients typically receive a statement of account performance for their
accounts under our management, along with written commentary discussing market
environment and important shifts in sentiment, valuation and outlook. Additionally, the
custodian of client assets will provide statements at least quarterly which detail account
securities holdings and account cash flows. Transaction confirmations will be provided by
the clearing broker at least quarterly.
Client Referrals and Other Compensation
Brokerage Support Products and Services
We receive an economic benefit from broker-dealers/custodians in the form of the support
products and services they make available to us and other independent investment advisors
whose clients maintain their accounts at the custodian. These products and services, how
they benefit us, and the related conflicts of interest are described above (see Brokerage
Practices). We do not base particular investment advice, such as buying particular
securities for our clients, on the brokerage products and services available to us.
Referral Arrangements
If an unaffiliated promoter introduces a client to Knightsbridge, we may compensate that
promoter through direct or indirect compensation in accordance with the requirements of
Rule 206(4)-1 of the Investment Advisers Act of 1940, and any corresponding state
securities law requirements. Knightsbridge pays any referral fee to the promoter from our
standard investment advisory fee.
The promoter will disclose at the time of the solicitation whether they are or are not a
current client of the firm; whether they will receive any cash or non-cash compensation for
the referral; and a statement that the receipt of compensation for a referral creates a
conflict of interest. In addition, the promoter will provide each prospective client with a copy
of a written disclosure statement disclosing the terms and conditions of the arrangement
between Knightsbridge and the promoter, including the compensation the promoter will
receive from Knightsbridge and any material conflicts of interest on the part of the
promoter as a result of the referral arrangement.
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Financial Information
Registered investment advisers are required in this item to provide clients with certain
financial information or disclosures about the firm’s financial condition if the adviser
requires the prepayment of more than $1,200 in fees per client, six months or more in
advance. Knightsbridge does not require such prepayment and does not foresee any
financial condition that is reasonably likely to impair our ability to meet contractual
commitments to clients; consequently, no additional financial disclosure is required.
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